The aerospace standards AS9100, AS9110 and AS9120 aim to establish minimum baselines for quality management systems for manufacturers, repair stations and stockist distributors, respectively. Companies are then audited against those standards in order to achieve “certification” by an accredited third party registrar; this certification can open access to contracts available from government agencies, OEMs and aerospace primes.

Prior editions of AS9110 and AS9120 included language about counterfeit part control, but the AS9100 standard – the most well-known of the three – did not. With the latest update to revision D, however, AS9100 brings manufacturers into the fold. Specifically, the standard’s clause 8.1.4 now requires:

The organization shall plan, implement, and control processes, appropriate to the organization and the product, for the prevention of counterfeit or suspect counterfeit part use and their inclusion in product(s) delivered to the customer.

The change is unlikely to affect some electronic assembly manufacturers who would have been operating with such awareness even prior to AS9100’s discovery of it. The vast majority of AS9100 users, however, are going to find themselves struggling with a generically-worded clause that invokes a critically important concept, forcing users to interpret it as best they can for their particular organization. History tells us that when standards are poorly worded, implementation and subsequent auditing rarely go well.

The best approach for all user organizations is to tailor their QMS so that it matches what they do, rather than a literal blow-by-blow mimicking of the AS9100 standard. This results in flexible, organic quality systems that eventually drive the greatest levels of compliance and improvement; however, this requires one to take the AS9100 standard and hammer it into shape around the company’s QMS, through interpretation, rather than shaping the QMS to fit the standard. The trick here is to do this as much as possible without pushing the interpretation so far that the organization no longer complies with AS9100.

As always, different companies will face different challenges based on their particular products and the materials they use. For manufacturing companies utilizing electronic components or assemblies, they should implement a counterfeit part control program that aligns with industry best practices and, to the extent that they apply, the AS5553 and AS6081 standards. Because those standards already exist, and so there is a mature and robust support infrastructure already in place to assist companies in understanding and implementing those standards. It will be important to implement only the aspects of those standards that apply to the organization, of course.

For aircraft or spacecraft contract manufacturers who typically don’t utilize electronic components, things get trickier. The AS9100D standard doesn’t distinguish specific rules for electronics vs. raw materials like metals or plastics, but a literal reading of the requirement doesn’t distinguish: they all need to be controlled. Machine shops struggle with understanding this, since it’s rare that anyone receives “counterfeit” steel bar stock or aluminum extrusions, but if we view this as another means of ensuring raw material conformity, it becomes easier to understand. This means ensuring raw materials are suitable through heat lot traceability and material test reports, and by ensuring only established, vetted and evaluated suppliers are used. “Grandfathering” established providers of such material – especially if they are large, established suppliers – is a perfectly acceptable first step.

Additional assurance may require getting additional documentation to know where your suppliers are buying their materials from, but in many cases the documentation they already provide might be sufficient; e.g., batch records, certificates of analysis, etc. AS9100 already had stricter traceability requirements than the more generic ISO 9001 standard for manufacturers, so aerospace manufacturers may find little to worry about.

One side note: more and more aerospace contracts also invoke conflict-free mineral sourcing, and while that’s not included in AS9100, if you are already assessing conflict-free sources, this helps in meeting the new AS9100 requirements on counterfeit product, too.

It may not simply apply to raw materials, but also consumables and hardware kit components; however, if normal controls are implemented which aim to ensure the products are exactly what they claim they are – say, through receiving inspection and review of the accompanying certifications or documentation – you’ve done much of the work required to ensure they are not counterfeit.

AS9100D adopts the “risk-based thinking” approach of the latest revision of ISO 9001, and while controversial, this nevertheless gives AS9100 companies an additional tool to invoke when deciding on how much oversight to put into the various types of materials. It would be worthwhile for companies to do a simple risk assessment of all the types of materials they utilize, compared against historical evidence of counterfeiting and the risks to final products, to determine which materials it will apply counterfeit controls for, and which might only be managed through typical inspection and testing methods. For example, the world doesn’t have a history of counterfeit shipping labels or packing peanuts, so you might not want to invest a lot of time and effort on ensuring those; meanwhile, you will definitely want to put your efforts into the assurance activities of electronic components and, to a lesser degree, raw materials.

In all cases, if there is any suspicion about the origin of raw materials, the company should work to obtain enough documentation or evidence to alleviate that suspicion. It’s not one size fits all, and the rules for electronic counterfeit part control won’t work for raw materials or kit components. You must tailor the approach.

About Christopher:

Christopher Paris is founder of Oxebridge Quality Resources International LLC, http://www.oxebridge.com, a provider of AS9100 training and consultant. His clients include SpaceX, Northrup Grumman, NASA and more than 200 small to medium subtier suppliers. He is a vocal advocate for the rights of standards users, and is the author of the upcoming book Surviving ISO 9001: What Went So Terribly Wrong with the World’s Foremost Quality Management Standard, and How to Implement It Anyway.